Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 22775

Received: 28/02/2019

Respondent: Mr Robert Plumtree

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

The Priests Lane sites have been rejected previously because the land was deemed a valuable open urban space.

Change suggested by respondent:

The land at Priests Lane should be removed from the Local Development Plan.

Full text:

Unsound: I consider the plan to be unsound as the evidence base is flawed.
* The Transport Assessment is inaccurate as it has excluded traffic along Priests Lane and was taken at times which excluded a large proportion of school traffic, despite Council assurances that a traffic assessment would be done for Priests Lane.
* The Transport Assessment does not account for the increased usage of Priests Lane from the proposed development of 1,000 houses in Shenfield travelling to the A127, nor does it account for the impact of the Elizabeth Line.
* The Plan fails to address safety of residents: the technical submissions of residents that new road accesses along Priests Lane are hazardous have not been addressed, nor concerns that the road design is dangerous for increased traffic movements.
* The site does not met relevant sustainability conditions, notably access, transport network, mitigation of impact on local services and unacceptable effect on health due to increased pollution.
* The Priests Lane sites have been rejected previously because the land was deemed a valuable open urban space.
* No account has been made of the increased pollution along Middleton Hall Lane and Priests Lane, the junction of which is a pollution hotspot.
* Priests Lane was never meant to be a main distributary road which it has not become. Residents have pointed out that as such it does not comply with the Essex design guide with respect to road and pavement width.
NPPF Compliant: Local plans should address not only housing but traffic concerns, healthcare and education needs.
* The sustainability review refers to traffic as a concern, but no mitigation options have been identified.
* No specific or robust argument has been made that a viable access point is possible.
* When considered against reasonable alternatives these sites cannot be deemed justified and there is nowhere in the plan which allows for the enhancement of infrastructure as a result of development.
* There is no additional provision for increased educational and health needs, the expansion of Hogarth School is to meet current demands and there is already a low level of GPs per head. Schools further afield which may have space will require a car journey to attend, exacerbating the already dire traffic situation.
* The land at Priests Lane should be removed from the Local Development Plan as I do not consider the Local Plan to be sound or legally compliant.

Attachments: